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SCION


[30 August 2006]

[SUBMISSION: ENGLISH]



Question 1. Does your country have any plantations, either commercial or experimental, of genetically modified trees?
Yes.
An experimental field trial of 51 transgenic and five non-transgenic control pine trees is being conducted by Scion, a New Zealand Crown Research Institute.(http://www.scionresearch.com/environmental+risk+and+management.aspx). One hundred twenty eight cuttings from the 51 transgenic trees are also present in pots on the site. This trial was initiated in 2003 in a secure facility on the Scion campus in Rotorua, with the express purpose of assessing the impacts, if any, of transgenic trees on the environment. Additionally, the field trial was established to examine the long-term stability of transgene expression, which would be required in any commercial application of transgenic forestry. The field trial application was examined and approved by the New Zealand Environmental and Risk Management Authority (ERMA). The trial is audited on a biannual basis by Biosecurity New Zealand (http://www.biosecurity.govt.nz/), the regulatory agency within the Ministry of Agriculture and Forestry (MAF), charged with ensuring compliance under the Hazardous Substances and New Organisms (HSNO) Act (1996) (www.legislation.govt.nz/browse_vw.asp?content-set=pal_statutes). The trees contain the antibiotic resistance gene neomycin phosphotransferase (nptII), used as a marker for the initial selection of the genetically modified trees and as an expressed gene to assess the stability of gene expression. The trial is also an integral part of a New Zealand-wide initiative to assess and understand the environmental impacts of modern biotechnologies (also see Q3a).
Scion also has regulatory approval to conduct field trials on genetically modified trees for herbicide tolerance as well as suppression of development of male reproductive organs. However, the genetically modified plants have only recently been generated and are not yet ready for planting in the field trial site.
Scion (then Forest Research) also conducted a field trial of 33 transgenic trees and 3 non-transgenic controls between 1997 and 2002 for the purpose of the assessment of the stability of transgene expression in transgenic trees. Like the current field trial, the 1997 trial was conducted on the Rotorua campus under the oversight of ERMA. These trees contained the nptII transgene as described above, as well as the gene uidA, which encodes the enzyme _-glucuronidase, a common “reporter” enzyme used in plants (Jefferson et al., 1987). This trial was terminated in 2002, in compliance with its approved term.
Question 2. Has your country developed any platform/discussion forum/national committee etc. dealing with genetically modified trees?
Yes.
Royal Commission
In 2000/2001, the New Zealand government appointed a Royal Commission on Genetic Modification of Organisms (GMOs), including forestry trees. The Commission held 13 weeks of formal hearings, read more than 10,000 written submissions from the public and considered evidence from experts in New Zealand and overseas. After 14 months of deliberation, the findings and recommendations of the Royal Commission to the New Zealand government were published in 2002 and are available at http://www.mfe.govt.nz/publications/organisms/royal-commissiongm/index.html. A key finding of the Commission was that there is nothing inherently unsafe about genetic modification and that the application, not the methodology, is the key risk issue. The commission concluded genetic modification “holds exciting promise, not only for conquering diseases, eliminating pests and contributing to the knowledge economy, but of enhancing the international competitiveness of the primary industries so important for our country’s economic well being. We would be unwise to turn our back on the potential advantages on offer, but we should proceed carefully, minimising and managing risks.”
The Commission also concluded that New Zealand should keep its options open in developing plant and medical biotechnology based on GMOs and proceed carefully, minimizing and managing risks. The Government of New Zealand accepted this conclusion and has subsequently implemented many of the Commission’s recommendations (http://www.mfe.govt.nz/issues/organisms/lawchanges/ commission/index.html), including the call for more research on the potential environmental impacts of this technology. Since 2002, several programmes of such research have been funded by the New Zealand Government’s Foundation for Research, Science and Technology (FRST). The Scion field test of genetically modified trees is one of these programmes. The result is that we now have a robust, certain and transparent process for consideration of issues about release of GMOs into the environment.
Life Science Network
In addition to the Royal Commission, scientists representing many of the Crown Research Organisations, Universities, other research organisations, food growers and manufacturers established The Life Sciences Network. This was a nationally coordinated discussion forum and was instrumental in shifting the public and policy debate onto a much sounder basis by balancing arguments with factually-based information. (See www.lifesciencenetwork.com)
Public engagement and outputs
Finally, although not co-ordinated nationally, scientists from many organisations have been available to their local communities for public debates, seminars and disseminating information to interested parties about their research on GM. Scion research scientists have also published their opinions and research on the impact of genetic engineering on forestry (eg Walter 2004; Walter and Fenning, 2004; Charity 2003; Charity and Klimazsewska 2006).
3. Does your country have any guidelines or regulations for minimizing the impacts of genetically modified trees for scientific and/or commercial purposes?

Yes.


(We note that Question 3, by addressing only the issue of minimizing impacts, assumes that the only impacts of genetically modified trees will be negative. The Scion field trial is specifically designed to address many of the questions regarding the potential positive or negative environmental impacts of transgenic forestry, including impacts on biodiversity. We further note that such field trials are being conducted because transgenic forestry offers a huge potential, recognized worldwide, for positive environmental, social, cultural and economic impacts. Our view is supported by the FAO Panel of Experts on Forest Gene Resources who reviewed the relevance and feasibility of biotechnology in forestry, globally, summarized at the following

link: http://www.fao.org/docrep/008/ae574e/ae574e00.htm. We request that the Secretariat recognize that positive impacts can also result from the application of transgenic forestry such as addressing the fundamental and urgently needed criteria of long-term sustainability in the commercial forestry context.)
New Zealand is thought to have some of the strictest guidelines and regulations in the world. The Hazardous Substances and New Organisms (HSNO) Act (1996) is the all-encompassing legislation that was brought in to protect the environment, people and communities from the adverse effects of hazardous substances and new organisms (including new plant, animal or micro-organisms developed through genetic modification). New Zealand’s HSNO Act covers all aspects of the use of GMOs in this country, from research with GMOs that is confined to laboratories, through research in greenhouses and in the field, to the potential use of such organisms for commercial purposes. The Act is administered by ERMA and specifically requires this regulatory authority to take into account:

(a) the sustainability of all native and valued introduced flora and fauna;

(b) the intrinsic value of ecosystems;

(c) public health;

(d) the relationship of Maori (New Zealand’s indigenous people) and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna and other taonga;

(e) the economic and related benefits to be derived from the use of a particular hazardous substance or new organism (including GMOs); and

(f) New Zealand’s international obligations.
Any development of transgenic trees in New Zealand must satisfy ERMA before it can proceed, and these are the conditions under which our field trial with transgenic pine trees is being conducted.
The main presiding body that makes decisions on applications to import, develop, or field test new organisms under the HSNO Act (1996) is the Environmental Risk Management Authority (ERMA). The Authority is required to consider and weigh up the adverse and beneficial effects of a new organism or substance on society, the environment and public health etc. The intention of the Authority is to make decisions in a way that recognizes that there are benefits as well as risks associated with new organisms and hazardous substances.
To mitigate any risks ERMA may apply controls (where relevant and possible) to the application (for example, housing the organism or substance in a specially designed laboratory).
The enforcement agency for ERMA is Biosecurity New Zealand (http://www.biosecurity.govt.nz/), a regulatory agency within the Ministry of Agriculture and Forestry (MAF)
If yes, please list them according to the categories below:
3a Environmental impacts of genetically modified trees (Example: effects on native ecosystems, use of herbicide)
The HSNO Act specifically requires that all applications to research or use GM technology in New Zealand have been first subjected to a stringent risk assessment procedure by ERMA (www.ermanz.govt.nz). This procedure places great importance on preserving the sustainability of New Zealand’s productive and wild ecosystems and requires applicants to provide extensive information on the potential environmental impacts of any GMO, even if it is only for research purposes, before permission is given for their use.
For the field trial of transgenic trees noted in the response to Question 1, there are a number of regulatory requirements to which we adhere:

1. The trees were required to be transformed by a means other than by use of Agrobacterium-based methods.

The trees in our field trial were transformed by means of biolistic transformation technology

2. The trees are limited to five metres in height.

None of the trees in our field trial have yet reached this height

3. Only one main shoot is allowed to elongate above the length of 3 metres.

Others must be trimmed.

Trees are monitored weekly (see 5 below) and trimming is performed as required

4. The trees are to be destroyed if any evidence of male reproductive organs is found, and only one female reproductive cone is permitted on any given tree. This structure is not to be allowed to mature or produce viable seed.

None of the trees in our field trial have yet shown any evidence of reproductive growth

5. The trees are to be monitored individually on a weekly basis to ensure that compliance with conditions 2-5 is being maintained.

The observations are recorded accurately in logbooks.

6. Staff and visitors are required to undertake specific training before entering the trial site, or be accompanied at all times by a person so trained. The field trial is maintained securely behind a four metre tall electrified security fence with a locked gate. The security of the fence is monitored by a local security company and any potential breaches of the perimeter would be immediately relayed to security personnel. As such, all visitors have been accompanied by a trained staff member. Training of staff members is carried out on an “as needed” basis.

7. A written record of visitors to the field trial site is to be maintained.

Names of visitors to the field trial are recorded accurately in logbooks.

8. The field trial is audited biannually by MAF to ensure compliance.

Audits of the field trial are conducted on a twice-yearly basis. All audits to date have been found to be compliant with the regulations.

9. The material must be destroyed by incineration or autoclaving at the completion of the field trial.

All trimmed and cut material from the trees is also incinerated on an “as needed” basis
Regulation 1 was established to prevent the possible introduction of a transgenic soil bacterium into the environment. However, recent studies have demonstrated that the risk of such introduction of Agrobacterium into the environment is essentially zero (Charity and Klimaszewska, 2005).

Regulations 2-5 were established to eliminate the possibility that transgenic pollen or seed could spread into the environment.


This field trial is an integral part of a New Zealand-wide initiative to assess and understand the environmental impacts of the presence of an antibiotic resistance gene. Assessments of the effects of the transgenic trees on soil microorganism populations have shown that to date we have observed no differences between control trees and transgenic trees (C. Walter, J. Lottman, M. O’Callaghan, unpublished data). Although we realize that horizontal gene transfer (HGT) is rare and difficult to detect, HGT has not been detected from transgenic pines to the surrounding microorganisms in our studies so far (C. Walter, T. Glare, unpublished data). The field trial is also assessing the long-term stability of gene expression, which is essential for the successful introduction of transgenic forestry on a commercial scale. To date, the expression of the transgene has been stable in transgenic trees tested at weekly intervals over a two year time period. This is an important result since it indicates the continued expression of transgenes over a long period of time which is a prerequisite to commercial forestry. All of the environmental and long-term gene studies are continuing.
The field trial research is also supported by a number of laboratory- and greenhouse-based research projects which have established contained systems for measuring the impacts of transgenic pine foliage on a variety of non-target and beneficial invertebrates from pine forests, e.g. the native herbivorous lepidopterans, the pine looper and several leafroller species, a hymenopteran parasitoid, and a carabid beetle predator. “Worst-case scenario” experiments with transgenic pine and other non forestry tree plants expressing a variety of proteins have shown no unexpected non-target impacts on these invertebrates (e.g. Burgess et al., 2004. Impacts of genetically modified pine (Pinus radiata) seedlings on native New Zealand leafrollers. Research Report commissioned by Forest Research (Scion)). This research, and related invertebrate studies at Scion’s field site (FRST Programme C10X0601; administered by HortResearch), is ongoing.
3b Cultural impacts of genetically modified trees

(Example: positive or negative impacts on indigenous and local communities and their traditional knowledge)


The HSNO Act (1996), like many New Zealand laws, makes specific reference to the principles of the Treaty of Waitangi (a treaty between the indigenous people of New Zealand (Maori) and early British colonists) which give present-day guidance to government on cultural matters in this country. The Act specifically requires ERMA to include consideration of the impacts of any GMO research, use or development on Maori culture. It particularly notes the relationship of Maori (New Zealand’s indigenous people) and their culture and traditions with their ancestral lands, water, sites, waahi tapu (sacred sites), valued flora and fauna and other taonga (treasures or useful items).
Scion has actively engaged with and communicated to Maori, with regard to the potential risks and benefits of genetic modification technology and its field trial, as part of its FRST-funded research programme (C04X0207). This was particularly important since both our 1997 and our 2003 field trials were planted on land belonging to local Maori. Scion has the support of the Mana Whenua hapu,(the local tribe) including the blessing of the current field trial by a local kaumatua (chief). This is supported by additional research in a separate FRST-funded programme (C06X0222; administered by HortResearch) in which a model for selecting species for non-target biosafety testing is being constructed. The model uses the pine forest ecosystem as an example and takes into consideration not only the potential ecological consequences of impacts on a non-target organism, but also the anthropocentric value placed on each organism, including special consideration of species valued by Maori.
In addition, as part of the Foundation of Research, Science and Technology

(FRST)-funded research programme, Forest Genetics for the Future – from the lab bench to the Forest (FRST programme number C04X0207), Scion scientists engage with and advise Maori, as to the potential risks and benefits of transgenic forestry to Maori and the wider New Zealand context. In 2002, Scion established a national advisory committee “Te Aroturuki”, which is working with scientists to develop a tikanga (values)-based framework for the engagement of scientists with Maori and of Maori with scientists, regarding the risks and benefits of new and controversial technologies, including genetic modification. The programme has produced a booklet, “Te Maramatanga o te Tipuranga – An update of Forest Research’s Field Trial of Genetically Engineered Trees” written for Maori, by a Scion-employed Maori student, which describes genetic modification and its potential risks and benefits, primarily in a forestry context. The booklet can be accessed at the following link: http://www.scionresearch.com/Portals/0/CWBErinaBook.pdf


3c Socio-economic impacts of genetically modified trees

(Example: positive or negative effects on quantity, quality and economic value of forest production; positive or negative impacts on livelihoods of communities)


The socio-economic impacts of the study, development or use of any GMO in New Zealand are investigated by ERMA as part of it risk assessment and management procedures. The HSNO Act specifically requires that the “the economic and related benefits to be derived from the use of a particular hazardous substance or new organism (including GMOs)” be considered in any risk assessment.
Social research with public
A tender was let by the NZ Foundation for Research Science and Technology on "Public Perceptions of Biotechnology" in 1997. A three year programme of research was funded which involved a large range of stakeholders. This was led by programme leader Ms Sue Muggleston, HortResearch. The programme involved technical providers, Food and Agriculture policy makers, environmental groups (eg Greenpeace), industry associations, science educators, social science interest groups (eg allergy groups), growers and producer groups and the public. The final report was presented in 2000 and was widely discussed and distributed in different media and public fora.
References
CHARITY, J.A. 2003: Is Genetic Engineering having an impact on forestry? Primary Industry Management. 6: 8;10.
CHARITY, J.A., KLYMASZEWSKA, K (2005) Persistence of Agrobacterium tumefaciens in transformed conifers. Environ. Biosafety Res. 4: 167-177
JEFFERSON, RA, KAVANAGH, TA, BEVAN, MW (1987) GUS fusions: _- glucuronidase as a sensitive and versatile gene fusion marker in higher plants. EMBO J. 6: 3901-3907
SEDJO, R (2001) Biotechnology’s potential contribution to global wood supply and forest conservation. Resources for the future, Washington D.C
WALTER C. 2004: Stability of novel gene expression in transgenic conifers: an issue of concern? Book chapter in Mujib, A., Cho, M-J., Predieri, S and Banerjee, S. (Edts): “In vitro application in crop improvement”. Science Publishers Inc., Enfield USA.
WALTER, C. 2004: Review: Genetic engineering in conifer forestry: Technical and social considerations. Invited paper, in print, “InVitro (Plant)”, September

2004.
WALTER, C., FENNING, T. 2004: Deployment of genetically-engineered trees in plantation forestry - An issue of concern? The science and politics of genetically modified tree plantations. In: Walter and Carson (edts): “Plantation Forest Biotechnology for the 21st Century”. Research Signpost, Kerala, India. pp 231- 240.


WALTER, C.; CARSON, M (Eds): “Plantation Forest Biotechnology for the 21st Century”. 2004 Research Signpost, Kerala, India. pp446
WALTER, C.; KILLERBY, S. 2004: Global study on the state of forest tree genetic modification. Contracted study, Food and Agricultural Organisation of the United Nations (FAO), Rome


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